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GAO-13-173R:
United States Government Accountability Office:
Washington, DC 20548:
December 7, 2012:
Congressional Committees:
Subject: Firms Reported to Have Sold Iran Refined Petroleum Products
or Engaged in Commercial Activities in Iran's Energy Sector:
Iran's involvement in illicit nuclear activities, support for
terrorism, and abuse of human rights have led the United States, as
well as other nations, to impose multiple sanctions in an attempt to
curb these activities.[Footnote 1] According to the Department of
State (State), the sanctions are intended to, among other things,
target sectors of the Iranian economy relevant to its proliferation
activities and block the transfer of weapons and technology related to
Iran's missile and nuclear programs. In authorizing sanctions on
entities engaging in certain transactions in Iran's energy sector,
Congress declared that it is the policy of the United States to deny
Iran the ability to support proliferation and terrorism by limiting
the development of Iran's energy sector.[Footnote 2] The Secretary of
State is responsible for determining whether a firm should be
sanctioned for its activities in Iran's energy sector.
The United States has imposed these sanctions through various
legislation and executive orders, including the Iran Sanctions Act of
1996 (ISA).[Footnote 3] On July 1, 2010, the President signed into law
the Comprehensive Iran Sanctions, Accountability, and Divestment Act
(CISADA) of 2010, which added new activities for which entities can be
sanctioned under ISA.[Footnote 4] As amended by CISADA, ISA provides
for sanctions to be imposed against persons, including foreign firms,
who engage in certain activities in Iran's energy sector, including
selling or providing Iran with refined petroleum products or investing
more than $20 million in the:
development of Iran's petroleum resources.[Footnote 5] On August 10,
2012, the President signed into law the Iran Threat Reduction and
Syria Human Rights Act of 2012 (ITRSHRA), which further amended ISA in
part by increasing the number of activities for which entities can be
sanctioned.[Footnote 6]
ITRSHRA also requires GAO to submit to the Congress a report "listing
foreign investors in Iran's energy sector" for the period beginning on
January 1, 2009. The list is "to include entities that exported
gasoline and other refined petroleum products to Iran," and "entities
involved in commercial transactions of any kind, including joint
ventures anywhere in the world, with Iranian energy companies." In
response to this requirement, this report identifies (1) firms
reported in open sources published between January 1, 2009 and
September 30, 2012 to have sold refined petroleum products to Iran
during that same time period; and (2) firms reported in open sources
published between January 1, 2005 and September 30, 2012 to have had
commercial activities in Iran's energy sector during that same time
period. In addition, we list the status of each firm's activity as of
September 30, 2012. ITRSHRA did not ask us to attempt to determine
whether the activities for which the firms are listed in our reports
met the legal criteria for sanctionable activities under the ISA, as
amended. We plan to issue a report in 2013 that will address other
aspects of our reporting requirement under this provision of the
ITRSHRA legislation.
To accomplish these objectives, we updated information included in
four prior GAO reports. Two of these reports, taken together,
identified firms reported in open sources published from January 2009
through December 2011 as having sold refined petroleum products to
Iran during that same time period.[Footnote 7] The other two reports,
taken together, identified firms reported in open sources published
from January 2005 through May 2011 as having engaged in commercial
activities in Iran's energy sector during that same time
period.[Footnote 8] This report updates the information in those
reports to include information from open sources published through
September 30, 2012. As we did in the previous reports, we reviewed
open source information, including industry and trade publications,
corporate reports and statements, and U.S. Securities and Exchange
Commission filings. Regarding petroleum product sales, we listed firms
that were reported in open sources to have sold Iran refined petroleum
products if, for example, at least three reputable industry
publications and/or the firm's corporate statements reported that the
firm had done so at some point between January 1, 2012 and September
30, 2012. We defined refined petroleum products to include gasoline,
kerosene, diesel fuel, and gas oil. Regarding commercial activities,
we included a firm on our list if, for example, at least three
reputable industry publications and/or the firm's corporate statements
reported the firm to have had commercial activities in Iran's energy
sector at some point between June 1, 2011 and September 30, 2012.We
defined commercial activity as a firm having signed an agreement to
conduct business; invested capital; held an interest in an Iranian
energy sector project; or received payment for the provision of goods
or services in connection with a specific Iranian oil, gas, or
petrochemical project. Regarding sales of refined petroleum products
and commercial activities, in cases where a report did not specify the
date of such activity, we used the report's date of publication for
the date of activity. We did not review the contracts and documents
underlying the reported transactions and activities and did not
independently verify the transactions and activities. We did not
attempt to determine whether the activities for which the firms are
listed in our reports met the legal criteria for sanctionable
activities under ISA, as amended. The Secretary of State is
responsible for making such determinations.
We sent a letter to each firm whose status we had listed as "active"
or "insufficient information available" in our January 2012 report on
refined petroleum sales or our August 2011 report on commercial
activities that had not responded to our previous attempt to contact
them, to request comment on activities identified by those open source
reviews. We subsequently sent a letter to each firm for which we found
at least three open source reports of new activity during our current
review period, to request comment on those activities. See enclosure I
for a full description of our scope and methodology.
We conducted our work from October 2012 to December 2012 in accordance
with all sections of GAO's Quality Assurance Framework that are
relevant to our objectives. The framework requires that we plan and
perform the engagement to obtain sufficient and appropriate evidence
to meet our stated objective and discuss any limitations in our work.
We believe that the information and data obtained, and the analysis
conducted, provide a reasonable basis for any findings and conclusions.
Results in Brief:
Our reviews of open sources published between January 1, 2009 and
September 30, 2012 identified a total of 17 foreign firms that were
reported to have sold refined petroleum products to Iran during that
same time period (see enclosure II). Our review of open sources
published from January 2012 through September 2012 indicated that only
1 of these 17 firms--Sytrol--was reported to have sold refined
petroleum products to Iran during that same time period. In addition,
our open source review and communication with firms indicated that 12
of the 17 firms were reported to have stopped selling these products
to Iran before September 30, 2012; however, our review did not
identify sufficient information to indicate either that the remaining
4 firms had continued to sell or ceased selling refined petroleum
products to Iran at some point between January 1, 2012 and September
30, 2012.
Our reviews of open sources published from January 1, 2005 through
September 30, 2012 identified a total of 42 foreign firms that were
reported to have had commercial activity in Iran's energy sector
during that same time period (see enclosure III). Our review of open
sources published from June 1, 2011 to September 30, 2012 indicated
that 7 of these 42 firms were reported to have engaged in commercial
activities in Iran's energy sector during that same time period. In
addition, our open source review and communications with firms
indicated that 19 of the 42 were reported to have withdrawn from
commercial activities in Iran by June 2011, and 8 more had withdrawn
from such activities as of September 30, 2012; however, our review did
not identify sufficient information to indicate either that the
remaining 8 firms had continued or ceased engaging in commercial
activity in Iran's energy sector at some point between June 1, 2011
and September 30, 2012.
Background:
Iran's economy and government rely heavily on revenues from its oil
and gas industry. According to the 2012 Central Intelligence Agency
World Factbook, Iran is the fifth-largest holder of proven oil
reserves in the world and petroleum accounts for approximately 80
percent of Iran's exports.[Footnote 9] Iran's crude oil production
peaked in 1978 and has not matched that peak since then because of a
high rate of natural decline in mature oil fields, limited investment,
and sanctions. IHS Global Insight found that Iran's oil sector will
require approximately $25 billion in annual investments to maintain
existing production and considerably more to develop and enhance
recovery techniques that could lift its daily output from an estimated
4.2 million barrels in 2011 to 5.8 million barrels by 2015.[Footnote
10] In addition, Iran has limited refinery capacity and has been
reliant on imports of refined petroleum products to meet domestic
demand for gasoline, according to the Department of Energy.
The August 10, 2012 enactment of ITRSHRA added additional requirements
and measures to ISA.[Footnote 11] ISA, as amended, provides for
sanctions to be imposed against firms that are determined to knowingly
sell or provide Iran with refined petroleum products that (1) have a
fair market value of $1 million or more, or (2) during a 12-month
period, have an aggregate fair market value of $5 million or more.
[Footnote 12] It also provides for sanctions to be imposed on
companies that are determined to have made investments of at least $20
million that directly and significantly contributes to the enhancement
of Iran's ability to develop petroleum resources.[Footnote 13] As
amended, ISA also provides for sanctions to be imposed against persons
who knowingly participate, on or after August 10, 2010, in a joint
venture established on or after January 1, 2002, where the Government
of Iran is a substantial partner or investor or where the Government
of Iran could receive knowledge or equipment not already available to
it that would enhance Iran's ability to develop domestic petroleum
resources.[Footnote 14] The President, who delegated certain
authorities under the act to the Secretary of State, may waive the
imposition of sanctions for these activities.[Footnote 15] State is
primarily responsible for implementing ISA as amended.
According to Open Sources, 17 Foreign Firms Sold Iran Refined
Petroleum Products at Some Point between January 1, 2009 and September
30, 2012:
Our reviews of open sources published between January 1, 2009 and
September 30, 2012 identified a total of 17 foreign firms that were
reported to have sold refined petroleum products to Iran during that
same time period (see enclosure II). Our review of open sources
published from January 2012 through September 2012 indicated that 1 of
these 17 firms--Syria's state-owned Sytrol--was reported to have sold
gasoline to Iran during that same time period (see table 1). We did
not attempt to determine whether the activities for which the firm is
listed met the legal criteria for sanctionable activities under ISA,
as amended. The Secretary of State is responsible for making such
determinations. The Secretary of State imposed sanctions on Sytrol on
August 10, 2012 for selling Iran 33,000 metric tons of gasoline valued
at over $36 million (see enclosure IV for a list of foreign firms
sanctioned by State pursuant to ISA, as amended).[Footnote 16]
Table 1: Foreign Firm Reported in Open Sources to Have Sold Refined
Petroleum Products to Iran at Some Point between January 1, 2012 and
September 30, 2012:
Firm: Sytrol;
Country[A]: Syria;
Status in GAO's January 2012 report: Not listed;
Status in current GAO report: Active.
Source: GAO analysis of open source information.
Notes: For the purposes of this report, we listed a firm's status as
"active" if, for example, three open sources published within the
specified time period reported that the firm sold refined petroleum
products to Iran during that same time period. A firm's status in the
current GAO report is based on open source reports published between
January 1, 2012 and September 30, 2012. See enclosure I for the full
scope and methodology.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[End of table]
In addition, our open source reviews and communications with firms
indicated that 12 of the 17 firms were reported to have stopped
selling refined petroleum products to Iran before September 30, 2012
(see enclosure II). Our review did not identify sufficient information
to indicate either that the remaining 4 firms had continued to sell or
ceased selling refined petroleum products to Iran at some point
between January 1, 2012 and September 30, 2012 (see table 2).
Table 2: Foreign Firms for Which There Was Insufficient Open Source
Information to Indicate Either That They Had Continued or Ceased
Selling Refined Petroleum Products to Iran at Some Point between
January 1, 2012 and September 30, 2012:
Firm: China Oil;
Country[A]: China;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Petróleos de Venezuela S.A.;
Country[A]: Venezuela;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Unipec;
Country[A]: China;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Zhuhai Zhenrong;
Country[A]: China;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available.
Source: GAO analysis of open source information.
Notes: For the purposes of this report, we listed a firm's status as
"active," "withdrawn," or "insufficient information available." We
listed a firm's status as "active" if, for example, three open sources
published within the specified time period reported that the firm sold
refined petroleum products to Iran during that same time period. We
listed a firm's status as "insufficient information available" if the
review of open sources published within the specified time period did
not identify sufficient information to indicate either that the firm
had continued to sell refined petroleum products to Iran during that
same time period (active), or that the firm had ceased making such
sales (withdrawn). A firm's status in the current GAO report is based
on open source reports published from January 1, 2012 through
September 30, 2012. See enclosure I for the full scope and methodology.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[End of table]
According to Open Sources, 42 Foreign Firms Engaged in Commercial
Activity in Iran's Energy Sector at Some Point between January 1, 2005
and September 30, 2012:
Our reviews of open source information published from January 1, 2005
through September 30, 2012 together identified 42 foreign firms that
were reported to have had commercial activity in Iran's energy sector
during that same time period (see enclosure III).[Footnote 17] Open
sources published from June 2011 through September 2012 reported that
7 of these 42 firms had engaged in such commercial activity since our
last report on this topic in August 2011 (see table 3). We did not
attempt to determine whether the activities for which these firms are
listed met the legal criteria for sanctionable activities under ISA,
as amended. The Secretary of State is responsible for making such
determinations.
Table 3: Foreign Firms Reported in Open Sources As Engaging in
Commercial Activity in Iran's Energy Sector at Some Point between June
1, 2011 and September 30, 2012:
Firm: China National Petroleum Corporation;
Country[A]: China;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active.
Firm: Daelim;
Country[A]: South Korea;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active.
Firm: Indian Oil Corporation Ltd.;
Country[A]: India;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active[B].
Firm: Oil India Ltd.;
Country[A]: India;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active[C].
Firm: ONGC Videsh Ltd.;
Country[A]: India;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active[D].
Firm: Sasol;
Country[A]: South Africa;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active[E].
Firm: Sinopec;
Country[A]: China;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Active.
Source: GAO analysis of open source information.
Notes: For the purposes of this report, we listed a firm's status as
"active" if, for example, three open sources published within the
specified time period reported that the firm engaged in commercial
activity in Iran's energy sector during that same time period. A
firm's status in the current GAO report is based on open source
reports published from June 1, 2011 through September 30, 2012. See
enclosure I for the full scope and methodology.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[B] Open sources, including the firm's annual report for 2011-2012,
reported Indian Oil Corp., Ltd. as having a 40 percent interest in
Iran's Farsi Block gas field; however, the firm notified us that
although negotiations had taken place, no agreements had been reached
and no contracts to develop the gas field had been signed, and it had
decided under the present circumstances not to pursue further work on
the Farsi block.
[C] Open sources, including the firm's annual report for 2011-2012,
reported Oil India Ltd. as having a 20 percent interest in the Farzad
B gas field in Iran's Farsi Block; however, the firm notified us that
although negotiations were held, no agreement had been reached and no
contracts to develop the gas field had been signed, and it had decided
not to pursue further work on the Farsi Block gas field under the
present circumstances.
[D] Open sources reported ONGC Videsh Ltd. as having a 40 percent
interest in the Farsi Block, an Iranian gas field; however, the firm
notified us that although negotiations were held, no agreements had
been reached and no contracts to develop the field had been signed,
and it had decided not to pursue further work on the Farsi Block gas
field under the present circumstances.
[E] Open sources reported that Sasol is currently trying to divest its
joint venture.
[End of table]
In addition, our open source reviews and communications with firms
indicated that 19 of the 42 firms were reported to have withdrawn from
such commercial activity before June 2011, and that 8 more were
reported to have withdrawn from such activities by September 30, 2012
(see enclosure III). Our review of open sources did not identify
sufficient information to indicate either that the remaining 8 firms
had continued to engage or had ceased engaging in commercial activity
in Iran's energy sector at some point between June 1, 2011 and
September 30, 2012 (see table 4).
Table 4: Foreign Firms for Which There Was Insufficient Open Source
Information to Indicate Either That They Had Continued to Engage or
Had Ceased Engaging in Commercial Activity in Iran's Energy Sector at
Some Point between June 1, 2011 and September 30, 2012:
Firm: Amona;
Country[A]: Malaysia;
Status in GAO's August 2011 report: Insufficient information available;
Status in current GAO report: Insufficient information available.
Firm: China National Offshore Oil Corporation;
Country[A]: China;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Insufficient information available.
Firm: INA;
Country[A]: Croatia;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Oil and Natural Gas Corporation (ONGC);
Country[A]: India;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Petrofield;
Country[A]: Malaysia;
Status in GAO's August 2011 report: Insufficient information available;
Status in current GAO report: Insufficient information available.
Firm: Petróleos de Venezuela S.A.;
Country[A]: Venezuela;
Status in GAO's August 2011 report: Active;
Status in current GAO report: Insufficient information available.
Firm: Petronet LNG;
Country[A]: India;
Status in GAO's August 2011 report: Insufficient information available;
Status in current GAO report: Insufficient information available.
Firm: SKS Ventures;
Country[A]: Malaysia;
Status in GAO's August 2011 report: Insufficient information available;
Status in current GAO report: Insufficient information available.
Source: GAO analysis of open source information.
Notes: For the purposes of this report, we listed a firm's status as
"active," "withdrawn," or "insufficient information available." We
listed a firm's status as "active" if, for example, three open sources
published within the specified time period reported that the firm
engaged in commercial activities in Iran's energy sector during that
same time period. We listed a firm's status as "insufficient
information available" if the review of open sources published within
the specified time period did not identify sufficient information to
indicate that the firm had either continued to engage in commercial
activities in Iran's energy sector during that same time period
(active) or that the firm had stopped such activity (withdrawn). A
firm's status in the current GAO report is based on open source
reports published from June 1, 2011 through September 30, 2012. See
enclosure I for the full scope and methodology.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[End of table]
Agency Comments:
We provided a draft of this report to State for comment. State
declined to comment.
We are sending copies of this report to appropriate congressional
committees and the Secretary of State. In addition, the report is
available at no charge on the GAO website at [hyperlink,
http://www.gao.gov].
If you or your staff have any questions about this report, please
contact me at (202) 512-9601 or melitot@gao.gov. Contact points for
our Offices of Congressional Relations and Public Affairs may be found
on the last page of this report. GAO staff who made key contributions
to this report are listed in enclosure V.
Signed by:
Thomas Melito:
Director, International Affairs and Trade:
Enclosures - 5:
List of Committees:
The Honorable Tim Johnson:
Chairman:
The Honorable Richard C. Shelby:
Ranking Member:
Committee on Banking, Housing, and Urban Affairs:
United States Senate:
The Honorable Max Baucus:
Chairman:
The Honorable Orrin G. Hatch:
Ranking Member:
Committee on Finance:
United States Senate:
The Honorable John Kerry:
Chairman:
The Honorable Richard G. Lugar:
Ranking Member:
Committee on Foreign Relations:
United States Senate:
The Honorable Spencer Bachus:
Chairman:
The Honorable Barney Frank:
Ranking Member:
Committee on Financial Services:
House of Representatives:
The Honorable Ileana Ros-Lehtinen:
Chairman:
The Honorable Howard Berman:
Ranking Member:
Committee on Foreign Affairs:
House of Representatives:
The Honorable Dave Camp:
Chairman:
The Honorable Sander Levin:
Ranking Member:
Committee on Ways and Means:
House of Representatives:
[End of section]
Scope and Methodology:
To generate our list of firms that were reported to have provided
refined petroleum products to Iran, we used information in our earlier
reports on the sale of refined petroleum products to Iran for the
period from January 2009 through December 2011.[Footnote 18] Then we
updated that information by reviewing open sources published between
January 1, 2012 and September 30, 2012 to identify such sales reported
to have occurred during that time period. We searched open source
information that was determined to be credible and comprehensive by an
information specialist on our staff, who has conducted work on the
energy sector and worked for firms that conduct audits in the oil
processing industry, such as refining and petrochemical production.
For the purposes of our search, we defined refined petroleum products
to include gasoline, kerosene, diesel fuel, and gas oil. Open source
information is overt and publicly available information. We searched
English-language industry and trade publications for reports of such
activity by firms at any point during the period between January 1,
2012 and September 30, 2012. Our information specialist used the Nexis
Oil and Energy databases, which contain trade publications where more
than 60 percent of the stories pertain to the oil and energy
industries. Publications include Oil Daily, Oil and Gas News, Oil and
Gas Journal, and Platt's Oilgram News, among others. The information
specialist then screened the publications and excluded sources deemed
insufficiently reliable, such as newspaper reports, newswires, and
direct news releases from the Iranian government. We also reviewed
company publications, annual reports, U.S. Securities and Exchange
Commission (SEC) filings, Federal Register Notices, and press releases
and corporate statements reporting the sale of refined petroleum
products to Iran or for corrected information that had been publicly
reported.
To generate our list of firms that were reported to have had
commercial activities in Iran's energy sector, we used information in
our earlier reports on commercial activities in Iran's energy sector
for the period from January 2005 through May 2011.[Footnote 19] Then
we updated that information by reviewing open sources published
between June 1, 2011 and September 30, 2012 to identify firms that
were reported to have engaged in commercial activity in Iran's energy
sector during that period. To do so, we conducted searches in industry
publications and company reports and statements published between June
1, 2011 and September 30, 2012. For the purposes of our search, we
defined commercial activity as having signed an agreement to conduct
business, invested capital, held an interest in an Iranian energy
sector project, or received payment for the provision of goods or
services in connection with the Iranian oil, gas, or petrochemical
sectors. Our information specialist used the same English-language
sources that were used to identify sales of refined petroleum products
to Iran. The information specialist searched for the specific names of
firms identified in our 2011 report, as well as key terms such as
"Iran," within 25 words of "explore," "drill," "refinery," "natural
gas," and "petroleum." We also searched for locations in Iran where
oil, gas, and petrochemical activities were being conducted. In
addition, we reviewed company publications, including annual reports;
SEC filings, if available; press releases and corporate statements
that publicly reported their commercial activities in Iran; or
corrected information that had been publicly reported. We excluded
companies that reported purchasing crude oil or natural gas from Iran
because these purchases did not meet our definition of commercial
activity in Iran's oil, gas, or petrochemical sectors. Our June 2011
through September 2012 review spans both the period preceding and
following the enactment of the Iran Threat Reduction and Syria Human
Rights Act of 2012.[Footnote 20] We identified firms reported as
having contracts, agreements, and memorandums of understanding to
conduct commercial activity in Iran. We did not determine whether the
agreements represented final contracts or memorandums of
understanding, which are typically nonbinding agreements. When reports
varied about certain details of a firm's project, we presented the
information reported in the most recent source available.
For both lists, after identifying firms reported in open sources, we
confirmed that the reports were reliable and classified the firm's
status as "active" for this current reporting period if one of the
following criteria had been met: (1) at least three standard industry
publications reported that the firm had engaged in the identified
activity at any point during the specified time period; (2) the firm
provided information on its corporate website about the identified
activity at any point during the specified period, and at least one
standard industry publication corroborated the firm's activity at any
point during this period; or (3) the firm provided information in a
corporate report or an SEC filing, or confirmed in a letter to us,
that it had conducted the relevant activity during this period. If
none of these criteria were met, we did not list the firm as "active"
in our tables. We did not review the contracts or documents underlying
the transactions and activities reported in open sources and did not
independently verify these transactions and activities. We reviewed
open source information to identify the reported details of the
activities. In cases where dates of activity were not specified in the
reports, we used the date of publication for the date of activity. We
did not attempt to determine whether the identified activities met the
legal criteria for sanctionable activities under the Iran Sanctions
Act of 1996, as amended.[Footnote 21] The Secretary of State is
responsible for making such determinations.
We sent a letter to each firm whose status we had listed as "active"
or "insufficient information available" in our January 2012 report on
refined petroleum product sales or in our August 2011 report on
commercial activities and who had not responded to our previous
attempt to contact them, to request comment on activities identified
by those open source reviews. We subsequently sent a letter to each
firm for which we found at least three open source reports of new
activity during our current review period, to request comment on those
activities. We searched each firm's official website or the Internet
to identify its contact information. If we were unable to confirm
delivery of a letter to a firm or find a working address, we (1) e-
mailed the firm a letter containing the open source information we had
identified and (2) made at least three attempts to contact the firm by
telephone during the normal business hours of its headquarters
location. As of December 3, 2012, 12 of the firms had responded. We
have incorporated their comments into our findings, as appropriate.
We listed a firm's status as "withdrawn" if three separate open
sources published during the specified time period reported that the
firm had ceased the activity and/or the firm notified us that it had
ceased the activity. If our only source of evidence that a firm had
ceased the activity was a notification to us from the firm, we listed
the firm as "withdrawn" only if our open source review found no new
reports of the activity since our last report. If a firm was listed as
"withdrawn" in our last report, we continued to list it as "withdrawn"
in this report if we did not identify three open source reports
indicating that it had made sales of refined petroleum products or
engaged in commercial activities within the specified time period.
For the purposes of this report, we listed a firm's status as
"insufficient information available" if our review of open sources
published within the specified time period did not identify at least
three open source reports indicating whether the firm had continued or
ceased selling refined petroleum products to Iran or engaging in
commercial activities in Iran's energy sector. For example, if a firm
previously listed as "active" or "insufficient information available"
was identified in one or two open source reports as selling refined
petroleum products to Iran during the specified time period, we listed
the firm's status as "insufficient information available."
We conducted our work from October 2012 to December 2012 in accordance
with all sections of GAO's Quality Assurance Framework that are
relevant to our objectives. The framework requires that we plan and
perform the engagement to obtain sufficient and appropriate evidence
to meet our stated objective and discuss any limitations in our work.
We believe that the information and data obtained, and the analysis
conducted, provide a reasonable basis for any findings and conclusions.
[End of section]
Enclosure II:
Firms Reported in Open Sources to Have Sold Iran Refined Petroleum
Products at Some Point between January 2009 and September 2012:
Table 5 compiles information on foreign firms that were reported in
open sources published between January 1, 2009 and September 30, 2012
to have sold refined petroleum products to Iran at some point during
that same time period. It includes information presented in our
September 2010 and January 2012 reports.[Footnote 22] We did not
attempt to determine whether the activities for which the firms are
listed in our reports met the legal criteria for sanctionable
activities under the Iran Sanctions Act of 1996, as amended. The
Secretary of State is responsible for making such determinations.
Table 5: Foreign Firms Reported in Open Sources to Have Sold Refined
Petroleum Products to Iran at Some Point between January 2009 and
September 2012 and Comments Regarding Their Status:
Firm: Sytrol;
Country[A]: Syria;
Status in GAO's September 2010 report: Not listed;
Status in GAO's January 2012 report: Not listed;
Status in current GAO report: Active;
Comments: Open sources reported that the firm sold gasoline to Iran in
2012. The firm had not commented on our findings as of December 3,
2012.
Firm: China Oil;
Country[A]: China;
Status in GAO's September 2010 report: Active;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available;
Comments: Open sources published during our current period of review
provided insufficient information to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: Petróleos de Venezuela S.A.;
Country[A]: Venezuela;
Status in GAO's September 2010 report: Not listed;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available;
Comments: Open sources published during our current period of review
provided insufficient information to classify the firm as active or
withdrawn. During our previous reviews, open sources reported that the
firm sold petroleum products to Iran in 2011. The firm had not
commented on our findings as of December 3, 2012.
Firm: Unipec;
Country[A]: China;
Status in GAO's September 2010 report: Active;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient information to classify the firm as
active or withdrawn. The firm had not commented on our findings as of
December 3, 2012.
Firm: Zhuhai Zhenrong;
Country[A]: China;
Status in GAO's September 2010 report: Active;
Status in GAO's January 2012 report: Active;
Status in current GAO report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient information to classify the firm as
active or withdrawn. The firm had not commented on our findings as of
December 3, 2012.
Firm: Emirates National Oil Company;
Country[A]: UAE;
Status in GAO's September 2010 report: Active;
Status in GAO's January 2012 report: Insufficient information
available;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it had stopped selling gasoline to
Iran.
Firm: Glencore;
Country[A]: Switzerland;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. During our previous reviews, open sources reported that the
firm sold gasoline to Iran in 2009 but stopped in 2009. The firm
confirmed these reports.
Firm: Hin Leong Trading;
Country[A]: Singapore;
Status in GAO's September 2010 report: Active;
Status in GAO's January 2012 report: Insufficient information
available;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it had stopped selling gasoline to
Iran.
Firm: Independent Petroleum Group (IPG);
Country[A]: Kuwait;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: During our previous reviews, open sources reported that the
firm stopped selling gasoline to Iran in 2010. The firm confirmed that
it sold gasoline to Iran in 2009 and 2010.
Firm: Litasco;
Country[A]: Switzerland;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: During our previous reviews, open sources reported that the
firm sold gasoline to Iran in 2009 and 2010 but stopped in 2010.
Firm: Petronas;
Country[A]: Malaysia;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. During our previous reviews, open sources reported that the
firm sold gasoline to Iran in 2009 and 2010 but stopped in 2010.
Firm: Reliance Industries;
Country[A]: India;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in May 2009, and that its gasoline export contracts prohibit buyers
from selling its gasoline to Iran.
Firm: Royal Dutch Shell;
Country[A]: Netherlands;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in October 2009.
Firm: Total;
Country[A]: France;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in May 2010.
Firm: Trafigura;
Country[A]: Switzerland;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in November 2009. During our previous reviews, open sources reported
that it stopped in 2010.
Firm: Tupras;
Country[A]: Turkey;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in July 2010.
Firm: Vitol;
Country[A]: Switzerland;
Status in GAO's September 2010 report: Withdrawn[B];
Status in GAO's January 2012 report: Withdrawn;
Status in current GAO report: Withdrawn;
Comments: There were no open source reports of the firm selling
petroleum products to Iran during the time period of our current
report. The firm notified us that it stopped selling gasoline to Iran
in early 2010. During our previous reviews, open sources reported that
it stopped in 2010.
Source: GAO analysis of open source information.
Notes: The firms are listed in alphabetical order by activity status
in the current report.
For the purposes of this report, we listed a firm's status as
"active," "withdrawn," or "insufficient information available." We
listed a firm's status as "active" if, for example, three open sources
published within the specified time period reported that the firm sold
refined petroleum products to Iran during that same time period. We
listed a firm's status as "withdrawn" if, for example, three open
sources published within the specified time period reported that it
stopped selling refined petroleum products to Iran during that same
time period. We listed a firm's status as "insufficient information
available" if the review of open sources published within the
specified time period did not identify sufficient information to
indicate either that the firm had continued to sell refined petroleum
products to Iran during the same time period (active), or that the
firm had ceased making such sales (withdrawn). A firm's status in the
current report is based on open source reports published from January
1, 2012 through September 30, 2012. See enclosure I for the full scope
and methodology.
We listed British Petroleum in our September 2010 report because at
least three open sources reported that it sold refined petroleum
products to Iran at some point between January 1, 2009 and June 30,
2010, the period covered by our first review. The firm notified us
that it stopped selling gasoline to Iran in October 2008, but at the
time we did not find open source corroboration of the firm's
statement. After our report was issued, open sources confirmed the
firm's statement and indicated that the earlier open source reports of
the firm's activity were incorrect. Because we did not find three open
source reports of British Petroleum selling refined petroleum products
to Iran in any of our subsequent open source review time periods, we
removed British Petroleum from this list.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[B] For firms listed as "withdrawn" in the September 2010 report, we
found at least three open sources reporting that the firms had sold
refined petroleum products to Iran during the specified time period,
but also subsequently found at least three open sources reporting that
the firms had ended sales of refined petroleum products to Iran during
that same time period.
[End of table]
[End of section]
Enclosure III:
Firms Reported in Open Sources to Have Engaged in Commercial Activity
in Iran's Energy Sector at Some Point between January 2005 and
September 2012:
Table 6 compiles information on firms that were reported in open
sources published between January 1, 2005 and September 30, 2012 to
have had commercial activity in Iran's energy sector at some point
during that same time period. This table includes information
presented in our March 2010 and August 2011 reports.[Footnote 23] We
did not attempt to determine whether the activities for which the
firms are listed in our reports met the legal criteria for
sanctionable activities under the Iran Sanctions Act of 1996, as
amended. The Secretary of State is responsible for making such
determinations.
Table 6: Foreign Firms Reported in Open Sources to Have Engaged in
Commercial Activity in Iran's Energy Sector at Some Point between
January 2005 and September 2012 and Comments Regarding Their Status:
Firm: China National Petroleum Corporation;
Country[A]: China;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review reported that the firm has an interest in the project to
develop the Azadegan Oil Field. The firm had not commented on our
findings as of December 3, 2012.
Firm: Daelim;
Country[A]: South Korea;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. However, in response to our current review, the firm
contacted us and confirmed its involvement in the development of the
South Pars gas fields in Iran and its involvement in gas storage tanks
for an LNG project at Tombak.
Firm: Indian Oil Corporation Ltd.;
Country[A]: India;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources, including the firm's own annual 2011-2012
report, published during the period of our current review reported
that the firm has a 40% interest in the Farsi Block gas field.
However, the firm also notified us that the exploration period under
its exploration service contract had expired, that it had recently
been in negotiations with National Iranian Oil Company (NIOC) but no
agreements had been reached nor contracts signed for development of
the field, and it had no plans to pursue further work on the Farsi
Block.
Firm: Oil India Ltd.;
Country[A]: India;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review, including the firm's own 2011-2012 annual report, reported
that the firm has a 20% interest in the Farsi Block gas field.
However, the firm also notified us that the exploration period under
its exploration service contract had expired, that it had recently
been in negotiations with NIOC but no agreements had been reached nor
contracts signed for development of the field, and it had no plans to
pursue further work on the Farsi Block.
Firm: ONGC Videsh Ltd.;
Country[A]: India;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review reported that the firm has a 40% interest in the Farsi Block
gas field. However, the firm also notified us that the exploration
period under its exploration service contracts had expired, that it
had recently been in negotiations with NIOC but no agreements had been
reached, nor contracts signed for development of the field, and it had
no plans to pursue further work on the Farsi Block.
Firm: Sasol;
Country[A]: South Africa;
Status in GAO's March 2010 report[B]: Not listed;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review report that the firm is active in a joint venture in Iran but
is looking to divest. The firm recently stated that it is continuing
to engage with a number of interested parties in relation to the
firm's possible divestiture.
Firm: Sinopec;
Country[A]: China;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Active;
Comments: Open sources published during the period of our current
review reported that the firm has a 51% stake in Iran's Yadavaran
onshore oil field. The firm had not commented on our findings as of
December 3, 2012.
Firm: Amona;
Country[A]: Malaysia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: China National Offshore Oil Corporation;
Country[A]: China;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: INA;
Country[A]: Croatia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm notified us that while it had entered into a
service contract for the exploration and development of the Moghan 2
Oil Block in 2008, it had not conducted any activity under the
contract and had no plans to conduct any activity in Iran.
Firm: Oil and Natural Gas Corporation (ONGC);
Country[A]: India;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm notified us that it is not currently commercially
active with respect to any block, field, or project in Iran.
Firm: Petrofield;
Country[A]: Malaysia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: Petroleos de Venezuela S.A.;
Country[A]: Venezuela;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: Petronet LNG;
Country[A]: India;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: SKS Ventures;
Country[A]: Malaysia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Insufficient information available;
Comments: Open sources published during the period of our current
review provided insufficient reports to classify the firm as active or
withdrawn. The firm had not commented on our findings as of December
3, 2012.
Firm: Ashok Leyland Project Services (Hinduja Group)[C];
Country[A]: India (United Kingdom);
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: Open sources published during the period of our previous
reviews reported that the firm had withdrawn from commercial activity
in Iran. The firm recently notified us that it had made no binding
commitments or investments with respect to any oil or gas sector
projects in Iran.
Firm: Belneftekhim/Belarusneft;
Country[A]: Belarus;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Withdrawn;
Comments: Open sources published during the period of our current
review reported that the firm had withdrawn from all activity in Iran.
The firm confirmed to us that it had stopped conducting commercial
activity in Iran.
Firm: Costain Oil, Gas & Process Ltd.;
Country[A]: United Kingdom;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Daewoo Shipbuilding & Marine Engineering;
Country[A]: South Korea;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Edison;
Country[A]: Italy;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Withdrawn;
Comments: Open sources published during the period of our current
review reported that the firm had withdrawn from all activity in Iran.
The firm confirmed to us that it had stopped conducting commercial
activity in Iran.
Firm: ENI;
Country[A]: Italy;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Gazprom;
Country[A]: Russia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Withdrawn;
Comments: Open sources published during the period of our current
review reported that the firm had withdrawn from commercial activity
in Iran. The firm notified us that it had no current investment in
Iran's energy sector.
Firm: GS;
Country[A]: South Korea;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Haldor Topsoe;
Country[A]: Denmark;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Hyundai Heavy Industries;
Country[A]: South Korea;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report. The firm notified us that it had stopped conducting commercial
activity in Iran.
Firm: Inpex;
Country[A]: Japan;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: JGC Corporation;
Country[A]: Japan;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Lukoil;
Country[A]: Russia;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: LyondelBasell;
Country[A]: Netherlands;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: OMV;
Country[A]: Austria;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report. The firm notified us that it had stopped conducting commercial
activity in Iran.
Firm: Petrobras;
Country[A]: Brazil;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: PGNiG;
Country[A]: Poland;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report. The firm notified us that it had no commercial activity in
Iran.
Firm: PTT Exploration & Production;
Country[A]: Thailand;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Repsol;
Country[A]: Spain;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Royal Dutch Shell;
Country[A]: Netherlands;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Snamprogetti;
Country[A]: Italy;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Sonangol;
Country[A]: Angola;
Status in GAO's March 2010 report[B]: Not listed;
Status in GAO's August 2011 report: Active;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report. The firm notified us that it had stopped conducting commercial
activity in Iran.
Firm: StatoilHydro;
Country[A]: Norway;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Tecnimont;
Country[A]: Italy;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Insufficient information available;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report. The firm notified us that it had no commercial activity in
Iran.
Firm: Total;
Country[A]: France;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Turkish Petroleum Company;
Country[A]: Turkey;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Firm: Uhde;
Country[A]: Germany;
Status in GAO's March 2010 report[B]: Active;
Status in GAO's August 2011 report: Withdrawn;
Status in GAO's current report: Withdrawn;
Comments: There were no open source reports of the firm conducting
commercial activity in Iran during the time period of our current
report.
Source: GAO analysis of open source information.
Notes: The firms are listed in alphabetical order by activity status
in the current report.
For the purposes of this report, we listed a firm's status as
"active," "withdrawn," or "insufficient information available." We
listed a firm's status as "active" if, for example, three open sources
published within the specified time period reported that the firm had
engaged in commercial activities in Iran's energy sector during that
same time period. We listed a firm's status as "withdrawn" if, for
example, three open sources published within the specified time period
reported that it withdrew from its commercial activities in Iran's
energy sector during that same time period. We listed a firm's status
as "insufficient information available" if the review of open sources
published within the specified time period did not identify three open
sources reporting either that the firm had continued its commercial
activities in Iran's energy sector (active) or that it had ceased its
activities (withdrawn). A firm's status in the current report is based
on open source reports published from June 1, 2011 through September
30, 2012. See enclosure I for the full scope and methodology.
[A] The country listed in this column is the physical location of the
firm as reported in open sources.
[B] Because ITRSHRA mandated that we provide information since January
1, 2009, we have included information from the 2010 report, which
aggregated the data between 2005 and 2009.
[C] In response to our request for comment, Ashok Leyland Project
Services (ALPS) in India stated that it, rather than Hinduja Group in
the United Kingdom, should be identified as a firm appearing in the
table. According to the firm, ALPS is an independent board-managed
company.
[End of table]
[End of section]
Enclosure IV:
Foreign Firms Sanctioned by State under the Iran Sanctions Act of 1996
as Amended:
Since the enactment of the Comprehensive Iran Sanctions,
Accountability, and Divestment Act of 2010, the Secretary of State has
imposed sanctions under the Iran Sanctions Act of 1996, as amended, on
14 firms for the sale of refined petroleum products to Iran or for
investment in Iran's oil, gas, and petrochemical sectors.[Footnote 24]
In October 2010 and April 2011, State imposed sanctions on Naftiran
Intertrade Company and Belarusneft, respectively. In September 2011,
State imposed sanctions against Allvale Maritime Inc., Associated
Shipbroking, Petrochemical Commercial Company International, Petróleos
de Venezuela S.A., Royal Oyster Group, Société Anonyme Monégasque
D'Administration Maritime Et Aérienne, Speedy Ship, Tanker Pacific
Management Pte. Ltd. On January 12, 2012, State imposed sanctions on
Zhuhai Zhenrong, FAL Oil Company Limited, and Kuo Oil (S) Pte. Ltd.,
and on August 10, 2012, on Sytrol. According to State, the firms were
sanctioned for the following reasons:
* Petrochemical Commercial Company International, Royal Oyster Group,
and Speedy Ship were among the largest current suppliers of refined
petroleum products to Iran and all three regularly engaged in
deceptive practices in order to ship these products to Iran and evade
U.S. sanctions.
* Allvale Maritime Inc., Associated Shipbroking, Société Anonyme
Monégasque D'Administration Maritime Et Aérienne, and Tanker Pacific
Management were sanctioned for their roles in a September 2010
transaction that provided a tanker valued at $8.65 million to the
Islamic Republic of Iran Shipping Lines, an entity that has been
determined to have supported Iran's nuclear and missile programs.
* Petróleos de Venezuela S.A., the state-owned oil company of
Venezuela, delivered at least two cargoes of reformate, a blending
component that improves the quality of gasoline, to Iran between
December 2010 and March 2011, worth approximately $50 million.
* Zhuhai Zhenrong, the largest supplier of refined petroleum products
to Iran, brokered the delivery of over $500 million in gasoline to
Iran between July 2010 and January 2011.
* FAL Oil Company Limited, a large independent energy trader based in
the UAE, provided over $70 million in refined petroleum to Iran in
multiple shipments in late 2010.
* Kuo Oil (S) Pte. Ltd., an energy trading company, provided over $25
million in refined petroleum to Iran between late 2010 and early 2011.
* Belarusneft and Naftiran Intertrade Company were sanctioned for
their investment in Iran's energy sector.
* Sytrol, Syria's state-run oil company, sold 33,000 metric tons of
gasoline worth $36 million to Iran.
The sanctions prohibit, among other things, various commercial
activities in the United States or with U.S.-based firms.[Footnote 25]
To identify firms that sell refined petroleum products to Iran, State
officials indicated that State collects and reviews information from
numerous sources, including open source information, but relies on
information from numerous intelligence organizations, including
State's Bureau of Intelligence and Research, the Office of the
Director of National Intelligence, the Central Intelligence Agency,
and the Office of Naval Intelligence.
[End of section]
Enclosure V:
GAO Contact and Staff Acknowledgments:
GAO Contact:
Thomas Melito, (202) 512-9601 or melitot@gao.gov:
Staff Acknowledgments:
In addition to the contact named above, Pierre Toureille (Assistant
Director), Jeffrey Baldwin-Bott, JoAnna Berry, Debbie Chung, Martin de
Alteriis, Grace Lui, Michael Maslowski, and David Schneider made key
contributions to this report.
[End of section]
Footnotes:
[1] For example, see the Comprehensive Iran Sanctions, Accountability,
and Divestment Act of 2010, Pub. L. No. 111-195, 124 Stat. 1312 and
Council Decision 2010/413/CFSP Concerning Restrictive Measures Against
Iran and Repealing Common Position 2007/140/CFSP, 2010 O.J. (L 195) 39.
[2] Iran and Libya Sanctions Act of 1996, Pub. L. No. 104-172, § 3,
110 Stat. 1541. In this report, we use the term "energy sector" to
refer to Iran's oil, gas, and petrochemical sectors.
[3] International Emergency Economic Powers Act, Pub. L. No. 95-223,
91 Stat. 1625 (1977); National Emergencies Act, Pub. L. No. 94-412, 90
Stat. 1255 (1976), and 3 U.S.C. § 301 as implemented by Executive
Order 12957, 60 Fed. Reg. 14615 (Mar. 15, 1995) (prohibiting U.S.
involvement with petroleum development in Iran), Executive Order
12959, 60 Fed. Reg. 24757 (May 6, 1995) (banning specified exports and
investment), and Executive Order 13059, 62 Fed. Reg. 44531 (Aug. 19,
1997) (prohibiting virtually all trade and investment activities with
Iran by U.S. persons, wherever located). Iran and Libya Sanctions Act
of 1996, Pub. L. No. 104-172, as amended (the name of this law was
changed to the Iran Sanctions Act of 1996 by the Iran Freedom Support
Act, Pub. L. No. 109-293, 120 Stat. 1344 (2006)).
[4] Pub. L. No. 111-195, § 102, 124 Stat. 1312, 1317-28.
[5] Pub. L. No. 104-172, § 5, as amended. Sanctions related to the
provision of refined petroleum products Iran are authorized when the
refined petroleum products have a fair market value of at least $1
million or, during a 12-month period, have an aggregate fair market
value of at least $5 million. The act also allows for sanctions
against persons providing goods, technology, or services to Iran
knowing that such provision would contribute materially to Iran's
ability to acquire or develop chemical, biological, or nuclear weapons
or related technologies, or acquire or develop destabilizing numbers
and types of advanced conventional weapons.
[6] Pub. L. No. 112-158, 126 Stat. 1214.
[7] GAO, Firms Reported in Open Sources to Have Sold Iran Refined
Petroleum Products between January 1, 2009, and June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-10-967R] (Washington,
D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to Have Sold
Iran Refined Petroleum Products Declined Since June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-12-321R] (Washington,
D.C.: Jan. 24, 2012).
[8] GAO, Firms Reported in Open Sources as Having Commercial Activity
in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-10-515R] (Washington, D.C.: Mar. 23,
2010). GAO, Firms Reported in Open Sources as Having Commercial
Activity in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-11-855R] (Washington, D.C.: Aug. 3,
2011).
[9] Central Intelligence Agency, World Factbook, [hyperlink,
https://www.cia.gov/library/publications/the-world-
factbook/geos/ir.html], accessed on November 14, 2012.
[10] IHS Global Insight, "Iran," Energy: Report, viewed May 26, 2011.
IHS Global Insight provides economic and financial information for the
energy industry on a contract basis, including analysis and
forecasting for the Iranian oil, gas, and petrochemical sectors
discussed in this report.
[11] Pub. L. No. 112-158, §§ 201-208.
[12] Pub. L. No. 104-172, § 5(a), as amended.
[13] Pub. L. No. 104-172, § 5(a), as amended. The investment must be
either at least $20 million or a combination of investments of at
least $5 million which aggregates to at least $20 million in a 12-
month period.
[14] Pub. L. No. 104-172, § 5(a), as amended. Generally, ITRSHRA also
extended ISA sanctions to the following commercial activities: (1)
engaging in specific activities supporting Iran's refined petroleum
sector, (2) contributing to the development of infrastructure that
supports the delivery of refined petroleum in Iran, (3) transporting
crude oil from Iran, and (4) evasion of sanctions by shipping
companies. Pub. L. No. 112-158, Subtitle A. For sanctions to apply to
these activities, differing conditions such as dollar-value thresholds
must also be met. Pub. L. No. 112-158, Subtitle A.
[15] Pub. L. No. 104-172, §§ 4, 9, as amended, and Memorandum:
Delegation of Certain Functions and Authorities under the
Comprehensive Iran Sanctions, Accountability, and Divestment Act of
2010, 75 Fed. Reg. 67025 (Sept. 23, 2010).
[16] Public Notice 8040, 77 Fed. Reg. 59034 (Sept. 25, 2012).
[17] For the purposes of this report, we defined commercial activity
as a firm having signed an agreement to conduct business; invested
capital; held an interest in an Iranian energy sector project; or
received payment for the provision of goods or services in connection
with a specific Iranian oil, gas, or petrochemical project.
[18] GAO, Firms Reported in Open Sources to Have Sold Iran Refined
Petroleum Products between January 1, 2009, and June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-10-967R] (Washington,
D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to Have Sold
Iran Refined Petroleum Products Declined Since June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-12-321R] (Washington,
D.C.: Jan. 24, 2012).
[19] GAO, Firms Reported in Open Sources as Having Commercial Activity
in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-10-515R] (Washington, D.C.: Mar. 23,
2010). GAO, Firms Reported in Open Sources as Having Commercial
Activity in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-11-855R] (Washington, D.C.: Aug. 3,
2011).
[20] Pub. L. No. 112-158.
[21] Pub. L. No. 104-172.
[22] GAO, Firms Reported in Open Sources to Have Sold Iran Refined
Petroleum Products between January 1, 2009, and June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-10-967R] (Washington,
D.C.: Sept. 3, 2010). GAO, Firms Reported in Open Sources to Have Sold
Iran Refined Petroleum Products Declined Since June 30, 2010,
[hyperlink, http://www.gao.gov/products/GAO-12-321R] (Washington,
D.C.: Jan. 24, 2012).
[23] GAO, Firms Reported in Open Sources as Having Commercial Activity
in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-10-515R] (Washington, D.C.: Mar. 23,
2010). GAO, Firms Reported in Open Sources as Having Commercial
Activity in Iran's Oil, Gas, and Petrochemical Sectors, [hyperlink,
http://www.gao.gov/products/GAO-11-855R] (Washington, D.C.: Aug. 3,
2011).
[24] See Public Notice 8040, 77 Fed. Reg. 59034 (Sept. 25, 2012)
(imposing sanctions on Sytrol). See also Public Notice 7197, 75 Fed.
Reg. 62916 (Oct. 13, 2010) (imposing sanctions on Naftiran Intertrade
Company), Public Notice 7408, 76 Fed. Reg. 18821 (Apr. 5, 2011)
(imposing sanctions on Belarusneft), Public Notice 7585, 76 Fed. Reg.
56866 (Sept. 14, 2011) (imposing sanctions on Allvale Maritime Inc.,
Associated Shipbroking, Petrochemical Commercial Company
International, Petróleos de Venezuela S.A., Royal Oyster Group,
Société Anonyme Monégasque D'Administration Maritime Et Aérienne,
Speedy Ship, and Tanker Pacific Management (Singapore) Pte. Ltd.),
Public Notice 7776, 77 Fed. Reg. 4389 (Jan. 27, 2012) (imposing
sanctions on FAL Oil Company Limited, Kuo Oil (S) Pte. Ltd., and
Zhuhai Zhenrong Company).
[25] The available sanctions include prohibitions on: (1) export
assistance from the Export-Import Bank of the United States; (2)
licenses for export of U.S. military, "dual use," or nuclear-related
goods or technology; (3) private U.S. bank loans exceeding $10 million
in any 12-month period; (4) designation as a primary dealer in U.S.
Government debt instruments or service as a repository of U.S.
Government funds, if the sanctioned person is a financial institution;
(5) procurement contracts with the U.S. Government; (6) foreign
exchange transactions subject to U.S. jurisdiction; (7) banking
transactions, involving any interest of the sanctioned person, that
are subject to U.S. jurisdiction; (8) transactions with respect to
property and interests in property subject to U.S. jurisdiction; (9)
imports from the sanctioned person, in accordance with the
International Emergency Economic Powers Act; (10) ban on investment in
equity or debt of the sanctioned person; (11) exclusion (visa ban) of
corporate officers or principals of, or a shareholder with a
controlling interest in, the sanctioned entity; or (12) sanctions (any
of the above) on principal executive officers of sanctioned entities.
[End of section]
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